Let us examine the tax monitoring requirements and the VAT regime applicable to the transfer of yachts in Italy intended for the personal use of those taking up residence in the country
by Berardo Lanci*
It is clearly evident to everyone that, in recent years, Italy has become one of the most attractive countries for foreign individuals – whether from within or outside the EU – who decide to move to our country.
The reasons for this may vary, often linked to the application of one of the many favourable tax regimes, or simply to the choice to live in one of Italy’s many beautiful, traditional locations – and, we might say, perhaps even unique in the world. In light of this, two tax-related issues typical for yacht owners have recently come to the fore once again; we intend to outline them here, albeit briefly: the obligation to comply with tax monitoring requirements and the VAT regime governing the transfer to Italy of yachts intended for the personal use of those transferring to Italy.
As regards the first point, it should be noted that individuals who become tax residents in Italy are required to comply with the tax monitoring obligation, introduced by Decree-Law No. 167/1990, in relation to foreign investments and foreign financial assets held by way of ownership or other legal rights in real property. These include boats and pleasure craft registered in a foreign maritime register, regardless of whether their usual port of mooring or shipyard is in Italy. It should be clarified that not only the formal owners of such assets and investments held abroad are required to declare them, but also those who, whilst not being the direct owners, are considered the beneficial owners of the investments. Furthermore, where there are multiple rights over the same investment – such as bare ownership and usufruct – both the holder of the usufruct and the holder of bare ownership are subject to monitoring.
The growing interest among foreign individuals in moving to Italy raises tax issues of great significance for those who own yachts for private pleasure use.
It is, moreover, generally accepted – based on the relevant principles – that the monitoring obligation also applies to foreign pleasure craft held under a leasing contract, in which the leasing company holds ownership of the asset but the shipowner, resident in Italy, is the actual user.
To comply with the obligations in question, individuals who are resident for tax purposes in Italy must complete Section RW of their tax return. Completing Section RW does not automatically subject the foreign investment to taxation in Italy; rather, its purpose is to notify the tax authorities of the holding of foreign investments that may generate taxable income in Italy.
Of special importance in this regard is Resolution No. 172/E of 3 July 2009, in which the Italian Revenue Agency clarified that foreign vessels and pleasure craft – that is, those registered in a foreign maritime register – are considered foreign assets of a capital nature and must be declared in Section RW. Indeed, the ownership of a foreign boat or vessel by a resident individual constitutes a potentially taxable source of income in Italy, as is the case, for example, in situations of occasional charter or leasing.
Where an individual who moves to Italy continues to register their yacht in a non-Italian register, they will – in most cases – be required to comply with tax monitoring obligations and to notify the Italian Revenue Agency annually of their ownership of the yacht.
About the value to be declared in section RW, the taxpayer must refer to the purchase cost, as evidenced by the relevant supporting documentation, or to the market value. In this regard, it should finally be noted that the aforementioned tax monitoring obligations do not apply to all new residents who have opted for the tax regime referred to in Article 24-bis of the TUIR, as clarified, amongst other sources, by the Italian Revenue Agency in Circular No. 17/E/2017.
Another significant matter concerns the VAT regime applicable when a non-EU shipowner moving to Italy intends to bring their yacht with them. In particular, the question has arisen as to whether, in such cases, the yacht owner must follow the standard import procedure, including payment of VAT, or whether they may benefit from the VAT exemption on the importation of personal effects by persons transferring their residence to a Member State. When asked about this matter, the Italian Revenue Agency clarified the applicable regime in Ruling No. 105/2026.
In particular, the Italian Revenue Agency establishes, as a preliminary point, that the exemption scheme in question is applicable even though EU Directive 2009/132/EC, which provides for its application, has not been formally transposed into Italian law. Under the Directive, the VAT exemption therefore applies to goods intended for the personal use of a shipowner who is moving to Italy, and pleasure craft are expressly mentioned amongst these.
// Non-EU yacht owners are permitted to bring their yacht with them, as it is considered personal property under the EU Directive, without having to pay import VAT. //
Furthermore, to prevent any abuse of the provision in question, it is provided that, to benefit from the aforementioned exemption, the new resident in Italy must have had and used the goods in their previous place of normal residence for at least six months before the move. In this regard, in the aforementioned Ruling No. 105/2026, the Italian Revenue Agency has adopted an approach that is not strictly formal but rather more substantive, clarifying that “as regards the requirement of ‘possession’ of personal property, according to the case law of the Court of Justice of the European Union – to which reference must be made to ensure the uniform application of the Directive – this is to be understood as the economic availability of the property, that is, effective control over it”.
(The move to Italy – Barchemagazine.com – Excerpted from Barche, September 2026)
